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122 - If a pharma company with an OTC or BTC product creates a private branded website that is password protected and accessible only by physicians, it is understood that all company generated content on the site would be subject to PAAB review and approval. However, if the site also allows for user generated content such as discussions between physicians, physician blog posts, or other physician generated questions or commentary, how might this type of dynamic activity and content be viewed by PAAB? Particularly given this type of content would be in constant evolution. Please note that this content would be viewable only by registered Canadian physicians. Any advice or direction would be appreciated.
• Jennifer Carroll -
73 - What is the policy and scope of a PAAB review for Canadian-based websites by manufacturers to support their prescription drug products? Is there a required/preferred review cycle - such as one a year? How does PAAB assess information on the website that is outside of the Product Monograph per se (i.e. - information on the disease state, practical tips for patients managing/coping with their disease apart from drug therapy, links to other websites like a medical association's guidelines)?
• Jennifer Carroll -
48 - I have already submitted a product's website copy for PAAB approval; however I was hoping to receive clarification around the requirements for submitting the website layout to PAAB: Is it sufficient to send the design for a few of the different pages within the site, or would you prefer we submit all pages included within the site? Should we be submitting the design once the copy has been PAAB-approved, or can we submit simultaneously? Does PAAB like to review the actual website before launch? If you could provide a few details around website layout submission, it would be greatly appreciated. I've referred to explanatory note 6.5.11 for guidance.
• Jennifer Carroll